Trial Courts Cannot Strike PAGA Claims On Manageability Grounds

Today, the California Supreme Court issued its decision in Estrada v. Royalty Carpet Mills, Inc. In the much anticipated decision, the Court held that trial courts cannot strike claims brought under California's Private Attorneys General Act of 2004, California Labor Code section 2698, et seq., (the "PAGA") on manageability grounds. Resolving a conflict among the Courts of Appeal on this point, the Court explained that trial courts, as a general matter, do not have broad authority to dismiss claims. The Court emphasized that while Courts of Appeal have a broad array of tools at their disposal to manage PAGA claims, "given the structure and purpose of PAGA, striking such claims due to manageability concerns -- even if those claims are complex or time-intensive -- is not among the tools trial courts possess."